To answer OCFS executive responding to e-mails with a request for another meeting:
Though our requests are already very clear and reasonable, and we have demonstrated that our concerns are widespread and have been thoroughly discussed statewide for years, we are agreeable to an in-person meeting, if necessary.
In our recent research, we have also discovered the stark inequities between providers (specifically center-based childcares) in NYC versus other providers throughout the rest of NY state:
- NYC center-cased providers post a performance summary card on site instead of the rap sheet compliance history forms like the rest of the state
- Performance summary cards display the average number of serious violations found during inspections of the facility compared to the average number of serious violations found citywide and the total number of serious violations found during the previous 12 months of inspections.
- There are 3 violation types categorized by the type of violation (public health hazard, critical violation, and general violation), the level of threat to child health and safety, the compliance time and assurance measure, and possible outcomes.
- The regulations are half as long in NYC as the regulations for the rest of the state childcare centers
- There is a Business Owner’s Bill of Rights created by the Mayor’s Office and City Council and feedback tool to report any unprofessional behavior from city employees that does not represent the commitment to business owners in the Bill of Rights.
- The minimum staff-to-child ratios according to health code section 47.23 is also different for center-based programs in NYC
Our formal request for specific changes outlined in the original e-mail from 11/30 and represented by the attached documentation from California is also echoed by the practices that currently already exist in the State of New York. As providers in the same state in the same industry with the same mission, we are requesting the same rights.
Your urgent consideration and action is requested as a systemic reform is long overdue and there are elements of the current regulatory/enforcement process that infringe on our constitutional protections. We eagerly await your response.
NYS Childcare Providers
